What Is Exchange of Information on Request?
Exchange of Information on Request refers to a tax cooperation procedure under which one jurisdiction's tax authority asks another for information on identified taxpayers.
Also known as: EOIR, Exchange of Information Upon Request.
How Exchange of Information on Request works
Exchange of Information on Request starts when a requesting tax authority, having exhausted its usual domestic sources, sends a request to a treaty partner, and the requested authority checks whether the information is foreseeably relevant and obtainable before gathering and transmitting the data. Within the EU, Council Directive 2011/16/EU requires a reply as quickly as possible and no later than six months from receipt, or two months where the requested authority already holds the information. The requested Member State uses its information-gathering powers even without its own tax interest and cannot refuse solely because a bank or nominee holds the data, although grounds for any refusal are communicated. Treaties outside the EU follow comparable principles, but procedures and time frames vary.
Exchange of Information on Request vs Automatic Exchange of Information (AEOI)
Unlike Automatic Exchange of Information, which transmits predefined data on a schedule without prior request, Exchange of Information on Request is case-specific and depends on a justified request about identified persons.
Example
Illustrative example: Country A's tax authority audits a consultant who claims non-residence and asks Country C, under the applicable treaty, for the bank statements and director records of the consultant's company. Country C obtains the records from the local bank and registry and transmits them for use in Country A's assessment.
Common misconception
Myth: A foreign tax authority only receives data already filed under automatic reporting.
Reality: On request, a treaty partner can gather new information specifically for the requesting authority, including bank records, within the limits of the governing instrument.
Frequently asked questions
How long does an exchange of information request take?
Under Council Directive 2011/16/EU, an EU Member State answers an Exchange of Information on Request within six months of receipt, or two months where the information is already held; timelines under other treaties vary.
Can banking secrecy block an exchange of information request?
Within the EU, banking secrecy alone cannot block Exchange of Information on Request, because Council Directive 2011/16/EU prevents refusal solely because a bank holds the information; other instruments set their own conditions.
Related terms
- Automatic Exchange of Information (AEOI) — Most confused: scheduled bulk exchange without requests
- Exchange of Information — Umbrella concept covering all exchange forms
- Tax Information Exchange Agreement (TIEA) — Treaty type built mainly around requests
- Competent Authority — Authority sending and answering requests
Related guides
- Tax treaties and international taxation — Treaty articles underpin information requests
Sources
Last verified: 2026-10-08. This entry is general information, not tax or legal advice; rules vary by country and change over time.
